36. He has one of those districts.

The ones where it's effectively a one-party race.

For that matter, until the last few months, it was thought that Eric Cantor also had one of those districts...but now there's a fair chance Cantor may lose...and that's more of a chance than any previous challenger to Cantor has had and more of a chance than any challenger his GOP predecessor ever faced had.

Lesson: If you're a big enough dickhead, you can even lose a district gerrymandered to favor your party by a 20% margin.